West Culburra Mixed Use Subdivision

There is absolutely no grounds on which this submission makes any sense to expand this area given recent natural disasters and population growth or movement. The fact that the bush land is being eradicated at such a great rate in the pursuit of housing is solely based on greed. If the natural bushland is razed to the ground there is no going back and we will not have the sanctuary that this area is known for. I do not support this this development because I do not want the area to loose the wild life that exists within the bushland, the peace and space that it provides and the natural wonder that we can share with our children. Let's not make it into another Central Coast please. It is just ridiculous that the council has allowed the majority of the properties in Culburra and Orient Point to be holiday homes therefore restricting residential living.

15th February 2021
John B Kerr
78 The Lake Circuit
CULBURRA BEACH NSW 2540
Director, Industry Assessments, Planning and Assessments,
Department of Planning, Industry and Environment,
Locked Bag 5022
PARRAMATTA NSW 2124
Sealark Pty Ltd - West Culburra Concept Proposal (App. No. SSD 3846) – Public Submission
I declare that I have not made a reportable political donation in the previous two years.
I support this development for the following reasons
I support the West Culburra Proposal (App. No. SSD 3846) Public Submission for the following reasons:
The development has been majority supported by the community since the early 1990”s. The Shoalhaven City Council has fully endorsed the development.
It will provide greater opportunities for the first home buyer and for second home buyers to upgrade parcels of land.
The development stage will bring much needed employment to the area and help current business survive.
The development contains best practice water management and has no impact to the lake Wollumboola catchment.
The developer will be providing parks and sporting grounds for the community.
Now that the developer has appeased the minority this development has no reason not to go ahead.

I need some modern 55years and over home for my later years such as will be provided in this development

I object to the proposal. My full objection document is attached. The 10,000 character limit isn't sufficient for my full objection statement.

The number of dwellings within the West Culburra Development (WCD) is expected to increase the population of Culburra Beach from 3,464 to over 4,500 people (a conservative estimate based on the number of dwellings to be constructed) - an approximate 30% increase in population. While at the time of the report the population had a period of decline, the 2016 population number exceeds the 2006 number based on the past census reports, which was the primary justification for the development.

The reasons for my objection to the WCD are covered in the topics below:

The road safety planning of WCD is severely deficient for the following reasons:
1. The existing road are already in a poor condition and are not as safe as they should be;
A. The state of the roads currently needs significant attention and most have many bitumen patches, stretching from Kalandar Street in Nowra through to Culburra Road, entire road is in urgent need of resurfacing;
B. The road from Nowra to Culburra Beach needs widening to incorporate an appropriate width of shoulder for the whole length of the road. In the last 2 months a light commercial vehicle came off the road and hit a tree and the vehicle was written off;
C. The WCD should perform all additional maintenance of the roads to repair the damage from the many construction vehicles and trucks that will need to use the roads during construction. Before any works are progressed, the roads must be maintained to a satisfactory level to give WCD 5e standard to meet;
D. Recent road repair works that commenced in November 2019 are still incomplete and the repairs are disgraceful as they are not smooth, the shoulders are too narrow and the camber is incorrect. I have been told that road repairs are performed every year and based on the current performance, this would appear correct; and
E. Footpaths /shared paths for pedestrians and cyclists should be appropriately sized to encourage safe use of the road for all road users. There is insufficient information of the design for the shared spaces between WCD residents to assess the town safety. It must be noted that if the infrastructure is poorly planned they will not be used and result in greater short distance vehicle movements and contribute to additional green house gases.
2. The addition of residents so far away from the beach will require additional car parking to be constructed at the beach. If there is no additional parking, then the visitors to the beach will park in the local street which will increase pedestrian and cyclist risks.
3. The use of a roundabout to connect WCD to the existing Culburra Road is a poor planning decision on too many levels:
A. The existing speed limit would have to be changed from 100km/h speed limit to 50km/h well before the proposed roundabout for WCD will directly result in a longer commute for exiting residents and an impact to public transport timetables. If this is multiplied by the additional short trips for residents in WCD to Culburra this would impact local residents movements and increase commuting time;
B. The proposed roundabout will, by its design and placement, give road access priority to WCD residents over existing residents and the existing industrial estate when they approach and depart Culburra. This will increase travel times for Culburra residents in both directions; and
C. Space has been left at the roundabout for a future golf course. As there are already many golf courses, it is surprising that there would be satisfactory economics for another golf course. The spacing at the roundabout is for the golf course is not required.
A roundabout is the wrong solution. The only option that should be adopted is an intersection similar to the Jervis Bay Road/Princes Highway intersection which prioritises the through traffic to keep the traffic flowing and not increase the commute time for residents travelling to Nowra and Bomaderry.
4. There should be only one side road access onto the Culburra Road for the industrial area and stages 2, 3 and 4 of WCD. Additional intersections along Culburra Road will only increase travel times for the existing residents and increase the safety risks of having more contact points for vehicles, for 4,000 residents, there is a too much risk.
5. The addition of approximately 30% more people does not provide for an equivalent increase of existing local facilities such as car parking around the existing town shops. The result will be increased traffic with no space for parking. The result is people parking and having to cross more roads along with increased traffic will result is greater risk to pedestrians and other road users.

The sewage plant and its impacts have been underestimated:
1. Odour bloom mapping appears to be underestimated. The prevailing wind direction during summer months are strong north east and easterly breezes with a southerly change. We can clearly see from the odour bloom mapping that the sewage plant odour passes over the existing industrial area with the north east breeze and extends to Culburra Road. When there is an easterly breeze the bloom does not appear to travel an equivalent distance. Further study should be conducted after taking into account the removal of the existing vegetation and the addition of more industrial lots, possibly removing stage 2?
2. Sewage plant expansion not factored into plans. The mapping of the bloom appears to consider the existing plant yet the space has been retained for an expansion. The odour bloom calculations should be made as if there was an expanded sewage plant. The impact of the odour bloom could negatively impact a significant proportion of the stage 2 development and the new industrial area.
3. Industrial estate should not have the odour bloom. The industrial area should also not be impacted by the sewage plant. While the existing industrial area is clearly within the odour bloom, this should not be considered as ‘normal’ and work health and safety for people working in the industrial are must be taken into account. It is unsatisfactory for workers to be subjected to the odour bloom for 8 hours of a working day.
The odour bloom study has been unsatisfactorily conducted and the WCD needs to be reconsidered, potentially removing the stage 2 area.

Fire safety plan must be required for developments given the 2020 bush fires and their proximity to the WCD.
1. Property protection. The WCD is totally exposed to the south west for bushfires and there is only one access road for a town. An analysis of the 2020 bush fires and the prevailing wind direction should be reviewed to ensure this development will be safe both during construction and for the future residents.Ultimately the safety of people at a time of bush fire is always the priority, but as we are referring to the planning of a new development the attention must be placed on people’s property. A permanent fire break should be created to protect the WCD construction personnel and the eventual residents’ property before the area can be considered habitable. From the information provided, no planning has been done to protect property such as the establishment of appropriate fire breaks before construction to protect the construction people and property.
2. People protection. We should note that Lake Conjola has a population of approximately 500 and also one access road which required evacuation during last years bushfires. Ultimately the people were evacuated by water to safety and Culburra has boat access through Orient Point to the Shoalhaven River, we are taking into account 8 times the number of residents of Lake Conjola to be evacuated.
3. Volunteer protection. Minimum road widths and shoulders must be taken into account as part of the fire safety plan to protect the population and importantly the Rural Fire Services volunteers at risk.
The existing Culburra town largely has protection from bush fires by the lake and river.

The environmental assessment must consider the green house gas and carbon dioxide impacts of the WCD from both the existing town or the additional WCD residents:
1. Greenhouse gas impacts from the development itself have not considered in the WCD and elements on reducing greenhouse gases must be included such as:
A. Carbon offset during the development from construction vehicles and construction activities. It must be a requirement for construction to offset its impact by requiring vegetation to be planted to balance greenhouse gases from construction activities; and
B. Transport impact on greenhouse gas from planning decision effects of the existing population have not been included. For example, commuters greenhouse gas emissions are a function of travel type, distance and time. For Culburra Beach there is no change in the type or distance for existing residents but there will be an impact from increasing the transportation time from resulting in greater gases. More vegetation like what is to be planted around WCD should be planted around the retail area and along major roads as a possible compensation and uniformity with the WCD to make Culburra Beach have a consistent vista.

As a result, the WCD primary justification for the development does not exist and in my opinion it lacks appropriate planning for the environment, public safety and the creation and a pleasant living space for existing residents and potential future residents and should be rejected. The WCD will negatively impact me and other residents lifestyle and I do not support this development.

Be great for out town to develop and grow

I wish to state that I am against the West Culburra project in it's present state.
The location is in a delicate wetland area and that 47-hectare section of native forest is in the 20% of Shoalhaven bushland that was untouched by fire and so is more important than ever to wildlife as the region slowly recovers.
The area is also of cultural significance to the Jerringa People and I believe the developers have not spoken or enquired about how the Jerringa People feel about the development.
Shoalhaven Council were "informed" that 85% of the population of Culburra supported the development. I can vouch that at no time in the last 10 years have I ever been asked for my opinion of the development.

I would like to oppose the approval of the West Culburra Development proposal for a number of reasons.
Summary of the core reasons why this development does not make sense and would be detrimental to all concerned, with the exception of the developer, if it were to go ahead:
Environmental – how does Council justify the environmental impact this development will have; can Council prove there will be no future adverse reaction in the surrounding environment as a result of the development and why is Council not following the post-bushfire recommendations of another government department?
• Destruction of approximately 50 hectares of bushland in a government-recognised wetland.
• Region’s bushland already under strain after bushfires and the Department of Agriculture, Water and the Environment in a report on 20 March 2020 tells us that it is necessary to “… protect unburnt areas within or adjacent to recently burnt ground that provide refuge, as well as unburnt areas that are not adjacent to burnt areas, especially from extensive, intense fire."
• There has been no independent study to check if the developer’s solution to the issue of storm water runoff into the waterways is going to work, so far we are relying only on the developer’s word. And if they have failed to curtail the runoff issues, the local oyster industry will suffer horrific losses.
Why must we continue to destroy more bushland and local fauna habitats just to line the pockets of developers?

Economic – has Council independently checked that the economic claims by the developer are based on fact? What evidence is there that the economic claims put forward by the developer are true and realistic?
• Based on the developers own numbers Culburra has a large (78%) excess of retail space compared to Australian local averages. Yet it proposes adding a further 2,438 square metres of retail space. The end result of this, even after considering the expected population increase from the development, would be an even greater imbalance in retail space to population. This is likely to perpetuate the current retail vacancy rates and increase competition to existing businesses. On top of that there is no sorely needed re-development of our existing retail precinct in this plan. This development has the potential to lead to business failures in Culburra.

• The developer claims the development will create over 200 full-time equivalent jobs on an ongoing basis (post construction) in Culburra. The developer’s plan will see an even greater of retail space than we already have and will increase the size of our industrial precinct by 140% (vs a 24% increase in population). The job prediction numbers rely on an assumed full occupation by successful businesses of an over-developed retail sector and an over-developed industrial sector. Even in that happy scenario they assume that employment per square metre is far greater than current Culburra Beach businesses achieve. It is fantasy economics.

Cultural Heritage - have the Jerringa elders been properly consulted and listened to on the importance of this land?
• The Aboriginal Heritage assessment in 2012 identified aboriginal artefacts up to 100m South from the shore of the Crookhaven River and suggested they would likely extend with digging 200m or further south of the river, well within the revised development area.

Infrastructre overload – has Council considered how it will cope with the increased demand on infrastructure adding such a large number of people to the area will cause?
• Our roads in particular are already atrocious and in dire need of repair.
• There is already a shortage of GPs available locally and the regional hospital is already always at or over capacity.
• Has Council already lined up extra funding for extra police and ambulance services and expansion of the school?

In summary, this entire proposal which has been touted as for the benefit of the town of Culburra Beach and its residents, will benefit no one but the developers.

As a resident, I hold very grave concerns for this town.

Essentially I do not believe that the amended proposal addresses all the objections made by the IPC when the previous proposal was rejected.
I believe that the project rejection was the right decision, and even though the amended proposal is much smaller there are still major concerns - especially as it is likely that if the amended version was accepted it would then lead to a larger development in time.
There is much that could be done to 'develop' Culburra Beach without destroying the natural beauty that surrounds it. Building a whole new suburb on precious wildlife habitat and natural beauty is not the answer. Visitors come to our area to enjoy the natural environment, so if we have to build something, why not build an eco-resort? Sensitive to the land it inhabits as well as aboriginal history. Encouraging people to explore Curley's Bay by canoe or on foot at the water's edge. Linked to Culburra Beach by walking tracks and bike paths.
I am a local resident. I agree with the IPC's decision and I call on them to again, reject this new proposal. I have only chosen to remain anonymous because it seems that some in this town are unable to listen to alternative points of view without becoming abusive to those who think differently.

I totally support the changes that would come out of this West Culburra Concept Proposal going ahead. Over the years I have seen many changes to our town, shops and garages opening then not long after closing as these businesses have not been a viable proposition and therefore driving to Nowra for supplies. This would bring new homes & jobs to our area, parks for our children, shops to our residents, better roads and infrastructure for all to enjoy. Our children/grandchildren shall have the opportunity to enjoy the development that shall arise from new homes, new residents and everything that is being proposed.

see attachment

Please see attached.

Hi Patrick,
I would like to add to my existing submission from January this year, due to new information that has been revealed about the West Culburra development in the past three weeks. Note my strong objection to the Halloran Trust / Sealark proposal has not changed.
Since making my original submission, I have become aware of misleading claims presented to Shoalhaven City Council about community support for the development, which was used to bring a motion to formally support the subdivision. Cr Mitchell Pakes said there was "no contention" within the Culburra Beach community about the development and claimed some 85% of residents supported it. This is a complete fallacy and is indicative of the lack of consultation and non inclusion of many residents from the conversation about West Culburra dating back to early proposals in 2010. Further, this motion to support the development was made before the West Culburra proposal was even released on public exhibition, illustrating the close ties to Shoalhaven City Council with developers and the landholder. Further, the only community meeting held since the West Culburra proposal was released was advertised as being for 'supporters only', with attendees instructed to register at a local real estate office prior to the meeting. This meeting was held in the Culburra Bowling Club, where Mitch Pakes is a current board member. I also do not believe that many residents or homeowners are aware of the linked Halloran Trust proposals for adjoining areas in Callala, Kinghorne Point and Currarong, and certainly do not understand that if the West Culburra proposal is approved, that this could pave the way for much larger-scale developments along the Crookhaven River and surrounding regions. You will note that SCC voted to support rezoning all lands under this proposal to make the process easier for the developer. I believe the complete lack of transparency and genuine consultation in relation to Halloran trust-owned land and council-appointed Community Consultative Bodies makes it untenable above and beyond the reasons I have already outlined in my submission.
You will also note that a petition started in response to community outrage about Cr Pakes' comments has generated more than 2000 signatures at the time of writing, and this is still increasing. While all signatures may not be from Culburra Beach residents, surely this calls into question the justification for SCC's premature and non-consultative support for the proposal and raises significant concerns about the proposed design. Culburra Beach has a huge tourism following and there are many visitors who have been coming to the town over a very many years to enjoy its pristine natural surroundings. To ignore the signatures on this petition would surely also be ignoring the views of such visitors and the significant tourism economy that Culburra Beach enjoys.
I have also talked to several members of the Jerrinja Local Aboriginal Lands Council in recent weeks and have become aware of serious problems with the proponent's approach to cultural and heritage preservation. A development site owned by Halloran Trust and currently under construction by Sealark Pty Ltd at East Crescent in Culburra Beach (on the shores of Lake Wollumboola) has uncovered significant Aboriginal heritage artefacts that indicate the predicted "minor" cultural significance of the site has been grossly underestimated by the developer in seeking its AHIP permit. Despite being issued a stop work request by JLALC, Sealark has failed to comply and is currently seeking to continue excavation works without meeting the Land Council's request for further consultation about the site. While I cannot speak on behalf of the Jerrinja people, I believe the current stalemate at East Crescent between the developer and JLALC illustrates the developer's cavalier approach to indigenous culture and history, and should serve as a loud warning to residents that their future developments will involve a similar disregard for the community and environment.
Finally, I have talked to several experts across multiple fields in the past three weeks, who have raised serious doubts about the developer's required assessments on water runoff, environmental impacts, housing affordability and retail space included in the West Culburra plans. A common theme among all these experts is that the developer's surveys are significantly out of date and often use flawed methodology to justify its position. In fact, many of the Halloran Trust's own reports contradict the Henry Halloran Trust's research into best practice urban planning at the University of Sydney. For example, in a paper commissioned by the Syd Uni's Henry Halloran Trust in 2020, research shows that "environmental capital is just as important or more important than extracational capital" however the Halloran Trust's documents for West Culburra arguably play down the value of the Crookhaven River catchment in favour of new housing. Similarly, in regards to retail space, the developer's proposal documents claim that Culburra Beach has too much retail space for a town of its size, but after new retail space in the development is considered, we will have 93% too much retail space. This needs urgent clarification from the developer.
Thank you for your close consideration of these issues, in addition to the early submission I have already lodged.
Lucy Robertson
(Culburra Beach resident and homeowner)

Thank you for considering the reasons I object to the proposed West Culburra development. There are quite a few…
I am not anti-development overall. I am, however, anti-inappropriate development and I feel that this proposal is best described in that fashion.
Culburra Beach is a small seaside community; the majority of permanent locals like it the way it is. The number of signatures gathered on the Change.org petition (close to 2500) indicates that a lot of locals are unhappy about the plans.
Of most concern to me is the impact it will have on the environment; the South Coast was devastated last year by the terrible bushfires and here we have a green corridor of bush that provides habitat for many native species, both flora and fauna; the wetlands act as both filter and lungs. The livelihoods of the world-famous oyster farmers at Greenwell Point are dependent on the quality of the water that hold their leases. If this development is allowed to go ahead, there will be no turning back, no second chance for an environment reeling from the fires and climate change. And heaven help us if a fire races through Culburra; there will be little chance of getting out safely with the extra cars that will become a part of daily life (instead of just the weekends and holiday periods).
Also of great concern is the number of lies told by the pro-development group; there has been deceit, secrecy, aggression and fearmongering spread throughout the community, fracturing it and causing great distress for many – particularly the elderly. There is at least one business in Culburra I try to avoid using because almost every time I go there I am subjected to loud banter between the proprietor and his cronies who discuss people who oppose the development in less-that-pleasant terms. The pro-camp are using manipulated figures to attempt prove their case and get their way. One of our local councillors recently had to retract figures quoted in a council meeting two weeks ago because they were way out of whack. The great furphies have been trotted out (yet) again; retail will suffer, Woolworths will close, the pharmacy will close – all lies. I contacted Woolworths last time and was told in no uncertain terms that they have no intention of closing, development or none, as they are a profitable store. The pharmacy has non-stop business from the aged care facility and already employs a large number of young locals. Culburra is actually thriving, with a new restaurant just opened and plans for more, including a boutique brewery in the old servo. There are three mechanics, two hairdressers, numerous cafes, two vet surgeries, a gym… What more do we need? We have plenty of shops empty; perhaps if landlords were a little less greedy they may hold onto a tenant for longer. The surf shop has moved premises three times in as many years thanks to the high rents in town. We could certainly use more GPs, but everything else is available a short drive away in Nowra.
There has been no community consultation this time; the only meeting held was limited to those who want the development to proceed. Why? What are they trying to hide? The meeting held at the bowls club in 2018 was a disgrace; men affected by alcohol catcalling and heckling anybody who dared oppose their opinion, and the meeting was held in the middle of a workday which limited the number of those who could attend. There are elderly women in Culburra Beach who have been menaced and are still being menaced by members of the pro-development mob when they are encountered in the street, as a direct result of that meeting.
From what I have read online, there has also not been adequate consultation with the Jerrinja Elders as to the impact on Country for them.
It appears to me that this is a bunch of rich old white men wanting to become infinitely richer at the expense of a small town quite happy (mostly) to stay a small town. On my infrequent trips to Sydney to visit family and friends, I shudder when I approach Shellharbour at the sight of all the matchboxes stacked cheek-by-jowl with each other, with barely a mature tree left. Is that the fate for Culburra? If this parcel of land is rezoned and hundreds of houses made of ticky tacky rise from the ashes of the bush, what will stop the Halloran Trust from developing all the land they own? Worrigee has been ruined by the developments off Old Southern Rd; we don’t need a development of this scale here. Houses with no green space around them, where the houses are so close together you can touch the walls of your neighbour’s house by just stretching out an arm.
There have been images circulated of West Culburra showing what a lovely pocket of natural bush it is. Please don’t allow it to be bulldozed to fill the pockets of people who don’t care. I will be dead and buried before the development affects me in any real form (apart from the bullying happening now) but we need to preserve Culburra for the good of future generations.
Yours sincerely,
Maggie Cooper (permanent resident)

The proposed development would result in very large numbers (thousand+) of additional domestic pets living in close proximity to Lake Wollumboola, with a consequent massive impact on birds in the area. Lake Wollumboola is currently an important bird nesting and feeding area, including some species of endangered birds.

I also endorse other objections about excessive development, environmental degradation.

I support first nations people's rights to control development on culturally significant sites.